This is a reminder to prepare for the 2016 Reporting Requirements, if you have not already done so.

Those affected are Applicable Large Employers (ALE’s).  ALE’s include those that are self-insured or have over 50 full time employees (including full time equivalent employees).  Commonly owned company’s count toward the ALE calculation.

Prepare for Compliance With Information Reporting Requirements

Information reporting is used to determine compliance with the ACA individual responsibility and “pay or play” provisions. While the information reporting requirements are first effective for coverage offered (or not offered) in 2015, the initial deadlines for reporting entities are in 2016.

  • Determine if you are a reporting entity (and what type) to understand applicable reporting requirements:
    • “Section 6055” Reporting Entities. Self-insuring employers that provide minimum essential health coverage are required to report information on this coverage to the IRS and to covered individuals under section 6055 of the Internal Revenue Code.
    • “Section 6056” Reporting Entities. Employers with 50 or more full-time employees (including FTEs) are required to report information to the IRS and to their employees about their compliance with “pay or play” under Internal Revenue Code section 6056-even those that qualified for 2015 transition relief from the “pay or play” provisions.
  • Begin compiling the required information for section 6055 reporting and/or the required information for section 6056 reporting.
  • Review the IRS Forms and Instructions to prepare for compliance:
  • Determine whether to hire a third party to fulfill reporting responsibilities (reporting entities will still be liable for the failure to report information and furnish employee statements).
  • For section 6056 reporting entities, determine whether you will use the general method of reporting or the simplified alternative method to satisfy the reporting requirements.
  • If the reporting entity plans to furnish employee statements electronically in 2016, ensure that affirmative consent is obtained from employees prior to furnishing (section 6056 reporting entities must also ensure that certain notice, hardware, and software requirements are met).
  • Remember to comply with the information reporting deadlines for calendar year 2015.

Section 6055 Deadlines:

  • First information returns must be filed no later than February 29, 2016 (or March 31, 2016, if filed electronically).
  • First employee statements must be furnished on or before January 31, 2016.

Section 6056 Deadlines:

  • First information returns must be filed no later than February 29, 2016 (or March 31, 2016, if filed electronically).
  • First employee statements must be furnished on or before January 31, 2016.

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